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ANALYSIS OF EMISSIONS REDUCTIONS FROM

PROPOSED EXCLUSION OF DECORATIVE HEARTH PRODUCTS

TABLE OF CONTENTS

1.1 INTRODUCTION ...............................................................................................................1

1.1.1 Alternatives..........................................................................................................................2

1.1.2 Analytical Methods for Air Emissions ................................................................................2

1.1.3 Effects on Household Emissions .........................................................................................2

LIST OF TABLES

Table 1.1.1 Alternative 1 (No Action) – Emissions impacts from April 2010 Final 

Rule, including standards for Decorative Hearth Products, as Compared to 

AEO 2010 Reference Case ......................................................................................3

Table 1.1.2 Alternative 2 (Action Alternative) -- Household Emissions Impacts for 

Hearth Products and Gas Logs Without Continuous Pilot Light or Other 

Source of Continuous Ignition as Compared to April 2010 Final Rule..................3
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1.1 INTRODUCTION

 This NOPR is closely related to standards set forth in an earlier DOE rule, namely DOE’s 

April 16, 2010, Final Rule, Energy Conservation Standards for Residential Water Heaters, 

Direct Heating Equipment, and Pool Heathers. 75 FR 201112 (April 2010 Final Rule). In that 

rule, DOE inter alia established exclusions for certain vented heating products (explicitly) and 

vented gas log sets (through a subsequent interpretation). The parts of this NOPR that might 

have an impact on the human environment do not establish new energy efficiency standards. 

Rather they revise the exclusion for certain decorative hearth products from the applicable 

energy conservation standards for “vented hearth heaters” in the April 2010 Final Rule. As one 

of the criteria to qualify for the exclusion, a decorative hearth heater is not permitted to have a 

pilot light or other continuously-burning ignition source. It is the elimination of these 

components that would result in additional reductions in energy consumption as compared to the 

reductions resulting from the April 2010 Final Rule. Decorative hearth products that qualify for 

the exclusion actually emit lower levels of air pollutants than products that precisely meet the 

existing standards. 

Pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4321 et 

seq.), the U.S. Department of Energy (DOE) prepared an Environmental Assessment (EA) of the 

potential impacts of the energy conservation standards for heating products in the April 2010

Final Rule. DOE included the EA as chapter 16 of the technical support document (TSD) for the 

April 2010 Final Rule. DOE found that the environmental effects associated with the energy 

conservation standards for heating products were not significant. Therefore, DOE issued a 

Finding of No Significant Impact (FONSI), pursuant to NEPA, the regulations of the Council on 

Environmental Quality (40 CFR parts 1500–1508), and DOE’s regulations for compliance with 

NEPA (10 CFR part 1021). The FONSI is available at DOE’s NEPA web-site. See 

http://nepa.energy.gov/documents/EA-1774FONSI.pdf (March 22, 2010).

Nothing in the instant Notice of Proposed Rulemaking (NOPR or Proposed Rule) alters 

DOE’s FONSI for the April 2010 Final Rule. This proposed rule would have beneficial impacts 

on the environment, but these impacts are a fraction of those resulting from the April 2010 Final 

Rule. To avoid redundancy, DOE does not here repeat qualitative information about pollutant 

impacts, relevant EPA regulations, and background information already set forth in the EA for 

the April 2010 Final Rule. For that analysis, please refer to Chapter 16 of the TSD for the April 

2010 Final Rule. See 

http://www1.eere.energy.gov/buildings/appliance_standards/residential/pdfs/htgp_finalrule_ch1

6.pdf (April 16, 2010). DOE’s limited purpose here is to identify additional emissions 

reductions that DOE anticipates would result from the rule proposed in the NOPR. Based on 

DOE’s review of these emissions reductions, DOE believes that the resulting, additional, 

beneficial impacts are so insignificant that the EA for the April 2010 Final Rule adequately 

addresses the environmental impacts from the Proposed Rule. 
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1.1.1 Alternatives

DOE does not here restate or reconsider the Trial Standard Levels for heating products 

and associated emissions reductions that DOE analyzed in the April 2010 Final Rule. That is 

because this NOPR is limited to proposing an exclusion from the particular standard (TSL 2) that 

DOE adopted in the April 2010 Final Rule. Thus, the alternatives considered here are (1) a No 

Action Alternative, which assumes that heating products, including decorative hearth heaters, are 

subject to the April 2010 Final Rule; and (2) an Action Alternative, which assumes that all 

manufacturers of decorative hearth heaters are granted an exclusion from the standards set forth 

in the April 2010 Final Rule. 

1.1.2 Analytical Methods for Air Emissions 

The operation of hearth products requires use of fossil fuels and results in emissions of 

carbon dioxide (CO2) and nitrogen oxides (NOX) at the sites where these appliances are used. 

Therefore, DOE calculated the effect of the performance measure on the above site emissions 

based on emissions factors derived from the literature. The emissions factors used are 50.6-68.6 

kg/Gigajoule (GJ) for CO2 and 40-66 g/GJ for NOX. For a more detailed discussion of how DOE 

calculates on-site emissions of CO2 and NOx, please refer to the EA for the April 2010 Final 

Rule. EA at 16-13, 16-14.

1.1.3 Effects on Household Emissions

Unlike some of the other products subject to the April 2010 Final Rule, decorative hearth 

products use natural gas, not electricity, as an energy source. As such, they do not indirectly 

affect emissions from electric generating units (EGUs). Rather, their impacts on the 

environment result from direct emissions of CO2 and NOX at the site of the product within the 

household.

Table 1.1.1 shows the total emissions reductions from all heating products under the 

April 2010 Final Rule (No Action Alternative). Table 1.1.2 shows the additional emissions

reductions that would result when residential hearth products and gas logs that lack standing pilot 

lights or other continuously-burning ignition sources are excluded from the April 2010 Final 

Rule (Action Alternative). The tables display changes in CO2 and NOX in selected years. There 

are no SO2 emissions impacts because the savings only come from natural gas, combustion of 

which does not release SO2. “Mt” refers to million metric tons.
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Table 1.1.1 Alternative 1 (No Action) – Emissions Impacts from April 2010 Final 

Rule, Including Standards for Decorative Hearth Products, as Compared 

to AEO 2010 Reference Case

Reference 2010 2015 2020 2025 2030 2035 2040 2044

Total 

2013-

2044

2010 Heating Products difference from AEO2010 Reference Case

CO2 (million metric tons) 0 0.738 -3.193 -6.07 -6.957 -6.957 -6.957 -6.57 -163.8

NOX (thousand tons) 0 0.565 -2.513 -4.67 -5.272 -5.272 -5.272 -4.915 -125

Hg (tons) 0 -0.023 -0.087 -0.146 -0.148 -0.148 -0.148 -0.135 -3.91

Table 1.1.2 Alternative 2 (Action Alternative) -- Household Emissions Impacts for 

Hearth Products and Gas Logs Without Continuous Pilot Light or Other 

Source of Continuous Ignition as Compared to 2010 Heating Products 

Final Rule

Additional Reductions Compared to April 2010 Final Rule

Reference 2010 2015 2020 2025 2030 2035 2040 2043

Total 

2013-

2043

CO2 (million metric tons) 0 -0.012 -0.098 -0.179 -0.227 -0.216 -0.216 -0.216 -4.95

NOX (thousand tons) 0 -0.009 -0.077 -0.142 -0.180 -0.171 -0.171 -0.171 -3.91

Notes: 1) The negative values represent emissions decrease in emissions.

2) With respect to Table 1.1.1 Cumulative total is over 2015 to 2044 for water heaters; cumulative total is over 2013 

to 2042 for direct heating equipment and pool heaters.

3) The AEO 2010 forecast ends in 2035. To be consistent, household emission impacts past 2035 are also assumed

to be equal to the impacts in 2035.